The Supreme Court has denied the petition of a police officer convicted of violating Section 5 (i) of Republic Act No. 9262, the Anti-Violence Against Women and their Children Act of 2004, for arbitrarily and publicly withdrawing a marriage license application against his pregnant partner. The Court affirmed the Court of Appeals ruling but modified the penalty of imprisonment.
The Case
The accused, referred to as XXX, a police officer, was charged with causing mental and/or emotional abuse to AAA, a public school teacher, by unilaterally withdrawing their marriage license application at the Office of the Local Civil Registrar (LCR), effectively breaking his promise to marry her.
According to the prosecution, XXX and AAA entered into a romantic relationship in 2019 after four months of courtship. In April 2020, AAA discovered she was pregnant, news which was positively received by the couple. Both families agreed the couple should marry and scheduled a visit to the LCR on June 1, 2020, to apply for a marriage license.
On the appointed date, XXX did not attend, having reportedly been called to a police operation. AAA felt utterly humiliated and ashamed, having already informed her family and friends of the impending marriage license application. Six days later, XXX apologized and requested a new schedule. On June 11, 2020, they lodged their application, but the following day AAA learned XXX had withdrawn it.
AAA was examined by Ms. Rovianne Lamsin, a Municipal Social Welfare Development Office (MSWDO) officer, who testified that AAA was "not in a stable psychological and emotional state." Dr. Marsha Molina, a psychometrician, testified that her tests revealed AAA suffered from restlessness, suicidal ideation, and depressive symptoms.
XXX admitted to the relationship and claimed his lack of communication was due to remote assignments with weak signals and police operations. He said their families, not he, set the date, and that he never expressly agreed to marry AAA. He admitted withdrawing his Certificate of Live Birth from the LCR but claimed he did so to use it for a firearm license application.
The Issue
The Court considered whether the Court of Appeals erred in affirming the conviction, given the petitioner's arguments that a breach of promise to marry is not an actionable wrong, that there was no consensual application, that the elements were not proven beyond reasonable doubt, and that his conviction was an improper expansion of Republic Act No. 9262.
The Ruling
The Court denied the petition. Its disposition reads: "FOR THESE REASONS, the Petition is DENIED. The assailed Decision dated April 30, 2025 and the Resolution dated September 16, 2025 of the Court of Appeals in CA-G.R. CR No. 04480 finding XXX guilty beyond reasonable doubt of violation of Section 5 (i) of Republic Act No. 9262 or the Anti-Violence Against Women and their Children Act of 2004 is AFFIRMED with MODIFICATION that petitioner is sentenced to suffer the indeterminate penalty of two years, four months and one day of prision correccional, as minimum, to nine years and four months of prision mayor, as maximum."
By the Numbers
- Offense date: June 10, 2020
- RTC Decision: December 4, 2023, in Criminal Case No. R-BAR-2021-001-CR
- CA Decision: April 30, 2025; CA Resolution: September 16, 2025
- RTC fine imposed: PHP 100,000.00
- Moral damages: PHP 75,000.00; exemplary damages: PHP 75,000.00
- Modified imprisonment: 2 years, 4 months and 1 day of prision correccional (minimum) to 9 years and 4 months of prision mayor (maximum)
- G.R. No. E-00648
The Court's Reasoning
The Court held that under Rule 45, its jurisdiction is generally limited to questions of law, and petitioner's arguments were laced with questions of fact seeking a recalibration of evidence already evaluated by the trial court and affirmed by the CA.
The Court explained that Republic Act No. 9262 focuses on the effect of the offender's acts—specifically the mental or emotional anguish caused to a woman with whom the offender had a sexual or dating relationship. Because AAA was pregnant and the withdrawal was done arbitrarily and publicly at the LCR, the act transcends simple heartbreak and enters the realm of psychological violence.
The Court found the elements of Section 5(i) established: petitioner admitted he and AAA had a sexual or dating relationship; he withdrew the marriage license application without notice after a public commitment; and the acts resulted in AAA's emotional anguish, confirmed by the MSWDO and a psychometrician who found suicidal ideation, depressive symptoms, and restlessness.
The Court rejected the claim of improper expansion, stating the law is a protective statute where an act used as a tool to inflict psychological trauma on a woman in a dating or sexual relationship must be interpreted to hold the offender liable. The RTC and CA did not penalize the breach of promise itself, but the willful withdrawal knowing the victim was pregnant and had announced the union, which constitutes emotional manipulation and public humiliation. The Court found the fine, mandatory counseling, and the moral and exemplary damages proper, but modified the imprisonment penalty.
Source: Supreme Court Decision in G.R. No. E-00648, penned by Associate Justice Ramon Paul L. Hernando.
This report summarizes a public Supreme Court decision and is not legal advice.